The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 introduce significant changes for regulated firms, particularly those involved in company formation and trust services.
Key changes
1. Off-the-shelf company sales brought into scope Firms that sell pre-formed companies are now expressly included as Trust or Company Service Providers (TCSPs). This closes a gap that was exploited for money laundering through shell companies.
2. Enhanced CDD for high-risk jurisdictions The list of high-risk third countries has been updated. Enhanced due diligence is now mandatory for all business relationships and transactions involving these jurisdictions.
3. Beneficial ownership verification The threshold for identifying beneficial owners remains at 25%, but firms must now take "reasonable measures" to verify the identity of beneficial owners, not just identify them.
4. Proliferation financing Counter-proliferation financing is now explicitly included alongside counter-terrorist financing obligations.
Timeline
- 30 June 2026 - Regulations come into force
- 31 December 2026 - Transitional period ends for existing business relationships
- Firms must update their policies, procedures, and training by the effective date
What firms should do now
1. Review and update your AML/CTF policies 2. Reassess your firm-wide risk assessment 3. Update CDD procedures for the new requirements 4. Retrain all relevant staff on the amendments 5. Review client files for any high-risk jurisdiction connections